Impeachment Material: NJ “Street Cop Training” Likely Unconstitutional-WA Cops Attended

Per Appendix B of the NJ Training Report, Washington Police Officers are among many states that have attended this “Street Cop Training” in 2021 in Atlantic City where officers were trained on “questionable polic...

Motion & Order for Witness Deposition Per CrR 4.6(a)

Motion provides the alternative to attend deposition via Zoom or in person with digital recorder rather than court reporter. [Remember that the advantages to obtaining a deposition are sworn testimony and the court reporter’...

Defense Discovery Deposition Motion

Combined order to compel the State to provide contact information for law enforcement and civilian witnesses, and to be allowed to audio tape or video tape record the interview in lieu of having a court reporter handle the deposit...

Prosecutor’s Brady Obligations

CPS-DSHS records requests PER AG

Motion for Sanctions and to Compel (2021)

Motion for sanctions for prosecutor who provided witness list with 223 witnesses most related to other case and refusing to narrow list. thanks to Shelley Ajax for sharing this brief.

Motion to Compel In-Person Interview or Deposition (3.2020)

This brief supports the defense motion to compel when the witness refuses to participate in an in-person defense interview, the witness is a critical witness and the only witness to the alleged crime. Thanks to Emily Gause.

Motion to Compel In Person Interview or Deposition (2009)

This brief supports the defense motion to compel in person interview or deposition when the witness lives out of state and the prosecutor refuses to pay for travel to permit a defense interview well in advance of trial.

Defense Objection to Protection Order for Child Forensic Interview Recording (3.2019)

This brief argues that RCW 26.44.186, which requires a court to issue a protection order governing the dissemination and use of audio and video recording of a "child forensic interview" is unconstitutionally vague, violates separa...

Order Denying Protection Order for Child Forensic Interview Recording FOF/COL (4.2019)

This sample court order denies the state's request for a protection order for the child forensic interview recording and the court enters findings of fact and conclusions of law holding RCW 26.44.186 is unconstitutional as it viol...